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collateral was received by the Trustee. The collateral shall be held in the name of the City. The <br />Trustee's records shall assure the notation of the City's ownership of or explicit claim on the <br />securities. The original copy of all safekeeping receipts shall be delivered to the City. <br />X. MANAGEMENT AND INTERNAL CONTROLS <br />The Director of Finance shall establish a system of internal controls, which shall be reviewed by <br />an independent auditor. The controls shall be designed to prevent losses of public funds arising <br />from fraud, employee error, misrepresentation by third parties, unanticipated changes in financial <br />markets, or imprudent actions by employees or Investment Officers of the City. <br />Controls and managerial emphasis deemed most important that shall be employed where <br />practical are: <br />A. Control of collusion <br />B. Separation of duties <br />C. Separation of transaction authority from accounting and record keeping <br />D. Custodian safekeeping receipts records management <br />E. Avoidance of physical delivery securities <br />F. Clear delegation of authority to subordinate staff members <br />G. Documentation on investment bidding events <br />H. Written confirmation of transactions for investments and wire transfers <br />I. Reconcilement and comparisons of security receipts with the investment subsidiary records <br />J. Compliance with investment policies <br />K. Accurate and timely reports <br />L. Validation of investment maturity decisions with supporting cash flow data <br />M. Adequate training and development of Investment Officers <br />O. Review of financial condition of all brokers, dealers and financial institutions <br />P. Staying informed about market conditions, changes, and trends that require adjustments in <br />investment strategies <br />Q. Monitor credit ratings <br />R. Monitor FDIC status for mergers and acquisitions for brokered CD's <br />COMPLIANCE AUDIT The City shall perform, in conjunction with its annual financial audit, a <br />compliance audit of management controls on investments and adherence to the entity's <br />established investment policies. The audit shall include a formal review of the quarterly <br />investment reports by an independent auditor and the results reported to the governing body by <br />the independent auditor. Also, the governing body shall review its investment policy and <br />investment strategy not less than annually and adopt a written instrument by rule, order, <br />ordinance, or resolution stating that it has reviewed the investment policy and strategy, and <br />recorded any changes made to them. <br />